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510(k) Data Aggregation
(264 days)
The Trinias is an angiographic X-ray system which is used for diagnostic imaging and interventional procedures. The Trinias is intended to be used for cardiac angiography, neurovascular angiography, abdominal angiography, peripheral angiography, rotational angiography, multi-purpose angiography and whole body radiographic/fluoroscopic procedures
Trinias is an interventional fluoroscopic x-ray system which uses digital x-ray receptor panels for image acquisition. The system has been modified to include new image enhancement software feature called "SCORE Opera." This new feature applies AI (deep learning technology) filter technology to enable efficient noise suppression and contrast enhancement, and to improve the visibility of devices that are generally difficult to achieve under low dose conditions, catheters for example.
The provided FDA 510(k) clearance letter and its associated summary for the "Trinias X-Ray System" (K252099) offer some details about the device's enhanced features and the studies conducted. However, it does not contain enough specific information to fully describe the acceptance criteria and the study that proves the device meets those criteria in the comprehensive manner requested.
Specifically, the document states:
- "The software was then subjected to non-clinical testing. Summary of non-clinical testing: We provided these detailed non-clinical test reports: The SCORE Opera Development process of leaning model AND a 2D Image Quality Evaluation Report."
- "Clinical testing: A clinical image quality study was conducted. The objective of the study was to evaluate the clinical image quality of X-ray images processed by the Trinias system's AI algorithm. The study aims to confirm that the AI-enhanced images (AI-ON) maintain diagnostic quality compared to standard image processing (AI-OFF). This assessment is submitted to support the determination of substantial equivalence. The results confirm that the AI-ON processing frequently provides improved visibility of interventional devices and vessels."
While these passages indicate that studies were performed, they lack crucial quantitative and qualitative details required to answer the specific questions below. The FDA 510(k) summary is generally an abbreviated public document; more detailed information would typically be found in the full 510(k) submission itself (which is not provided here).
Therefore, I will extract and present what can be deduced from the provided text, and explicitly state when information is missing.
Acceptance Criteria and Device Performance Study (K252099 - Trinias X-Ray System)
1. Table of Acceptance Criteria and Reported Device Performance
| Criterion Description (Inferred from Study Objective) | Acceptance Criteria (Not explicitly stated in the provided text, but inferred goal) | Reported Device Performance (From "Clinical Image Quality Study") |
|---|---|---|
| Clinical Image Quality: Diagnostic Quality | AI-enhanced images (AI-ON) must maintain diagnostic quality compared to standard image processing (AI-OFF). | "The results confirm that the AI-ON processing frequently provides improved visibility of interventional devices and vessels." |
| Clinical Image Quality: Visibility of Devices | Specific metric or threshold not stated. (Implied: Improve or at least not degrade visibility) | "Frequently provides improved visibility of interventional devices and vessels." |
| Noise Suppression & Contrast Enhancement | Specific metrics or thresholds not stated in document. | AI (deep learning technology) filter applied "to enable efficient noise suppression and contrast enhancement." |
| Safety and Effectiveness | Not to present any new issues of safety and effectiveness compared to predicate. | "Does not present any new issues of safety and effectiveness." "Performs as well as or better than our predicate." |
Missing Information: The document does not provide specific, quantifiable acceptance criteria (e.g., "AI-ON images must achieve a minimum diagnostic rate of X%," or "visibility scores must improve by Y points on a Z-point scale"). The reported performance is qualitative and comparative.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: Not specified. The document mentions "A clinical image quality study was conducted" but provides no details on the number of images or cases included in this study.
- Data Provenance: Not specified. The country of origin of the data (e.g., images) used in the clinical study is not mentioned. It is unclear if the data was retrospective or prospective.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
- Number of Experts: Not specified.
- Qualifications of Experts: Not specified.
4. Adjudication Method for the Test Set
- Adjudication Method: Not specified. No information is given on how discrepancies among experts (if multiple were used) were resolved or how the final "ground truth" for diagnostic quality and visibility was established.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- MRMC Study Done: Not explicitly stated as an MRMC study, but a "clinical image quality study" comparing AI-ON and AI-OFF was conducted. This type of study often involves human readers, which aligns with the spirit of an MRMC study, even if not formally named such. The document states, "The study aims to confirm that the AI-enhanced images (AI-ON) maintain diagnostic quality compared to standard image processing (AI-OFF)."
- Effect Size of Human Readers' Improvement with AI vs. Without AI Assistance: Not quantified or reported. The document only qualitatively states that "the AI-ON processing frequently provides improved visibility of interventional devices and vessels." It does not provide any statistical effect size or direct measure of how much human readers improved their diagnostic performance or speed with AI assistance.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
- Standalone Study Done: Yes, implicitly. The AI algorithm's function is described as processing images ("AI (deep learning technology) filter technology to enable efficient noise suppression and contrast enhancement"). The "2D Image Quality Evaluation Report" mentioned under non-clinical testing likely includes standalone evaluations of the algorithm's output before human review, though specific metrics are not provided in this summary. The clinical study compared images from AI-ON vs. AI-OFF processing, implying these are the outputs of the standalone algorithm before human interpretation.
7. Type of Ground Truth Used
- Type of Ground Truth: Inferred to be expert consensus or expert interpretation. For a "clinical image quality study" aiming to assess "diagnostic quality" and "visibility of interventional devices and vessels," the ground truth would most typically be established by experienced clinicians (e.g., interventional radiologists/cardiologists) who review and rate the images. The document does not mention pathology, outcomes data, or other objective measures for ground truth.
8. Sample Size for the Training Set
- Sample Size for Training Set: Not specified. The document mentions "The SCORE Opera Development process of leaning model" (likely meaning "learning model"), indicating AI/deep learning training, but no details about the size or characteristics of the training data are provided.
9. How the Ground Truth for the Training Set Was Established
- How Ground Truth Was Established (Training Set): Not specified. For a deep learning model, the training set would require labeled data. The method for generating these labels (ground truth) is not described. This could involve manual annotation by experts, consensus, or other automated/semi-automated methods, but the document is silent on this point.
In summary, while the K252099 document confirms that a clinical image quality study and non-clinical evaluations were performed to support the new "SCORE Opera" AI feature, it lacks specific quantitative acceptance criteria, sample sizes for test and training data, details on expert qualifications, and the formal methodologies for ground truth establishment and adjudication. The reported performance is qualitative, stating "improved visibility" and maintenance of "diagnostic quality."
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